MOUREEN CAMARA,PANAJI vs. ASSESSMENT CENTRE, INCOME TAX DEPARTMENT, DELHI

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 200/Pan/2023 Assessment Year : 2016-17 Moureen Camara Lonic Apartment, 1St Floor, Albamar Road, Tiswadi, Panaji, Goa-403001. Pan : Abmpc9038M . . . . . . . Appellant V/S Income Tax Officer, Ward-1(5), Panaji. . . . . . . . Respondent Appearances Assessee By : Mr D E Robinson [‘Ld. Ar’] Revenue By : Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing : 11/08/2025 Date Of Pronouncement : 26/08/2025 Order Per G. D. Padmahshali; Present Appeal Is Filed By The Assessee Challenging Din & Order No. Itba/Nfac/S/250/2023-24/1057640303(1) Dt. 02/11/2023 Passed By National Faceless Appeal Centre, Delhi [‘Ld. Cit(A)/Nfac’] U/S 250 Of The Income- Tax Act, 1961 [‘The Act’] Which In Turn Stemmed From Assessment Order Dt. 20/09/2021 Passed U/S 147 R.W.S.

148 of the Act, it does not obviate the mandatory requirement of the Assessing Officer having to issue to the assessee a notice under section 143(2) of the Act before finalising the order of reassessment

BARDC BANK,BHATKAL vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal filed by assessee is allowed

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.294/Pan/2024 (A.Y. 2013-14) Bardc Bank Bhatkal, Vs National E – Pld Bank, Main Road, Assessment Centre . Uttara Kannada, Delhi-110001 Bhatkal S.O. Karnataka-581320. Pan .No. Aaaap1731G (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 148 or to disclose fully 5 ITA. No. 294/PAN/2024 BARDC Bank. and truly all material facts necessary for his assessment for that assessment year” 6. Further we found that the A.O has issued notice u/s 148 of the Act dated 31.03.2021 for reopening of assessment. Whereas the original assessment was completed u/sec 143(3) of the Act vide order

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, 2, BELAGAVI

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 2, BELAGAVI

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SMT NEHA PRASANNA GHOTAGE,BELAGAVI vs. INCOME TAX OFFICER, WARD - 1, KARWAR

Appeals are DISMISSED

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

2) of section 249 of the Act. ITAT-Panaji Page 6 of 22 Neha Prasanna Ghotage Vs ACIT, Belgaum ITA No. 259 to 268/PAN/2025 AY: 2006-07 to 2010-11 10. Alike in former cases, opportunities provided to showcase ‘sufficient cause’ behind such belated filings in these cases also went futile as no evidence and explanations were filed

SUNIL HANAMANT NAIKWAD,BELGAUM vs. INCOME TAX OFFICER, WARD - 2, BELAGAVI

The appeal is ALLOWED as above

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Year : 2012-13 Sunil Hanmantsa Naikwad 1156, Saraf Galli, Shahapur, Belgaum Pan:Abeph0397N . . . . . . . Appellant V/S Income Tax Officer, Ward-2, Belgaum. . . . . . . . Respondent

reassessment of escaped income, and which he intends to taken into accounts, he would be required to issue a fresh notice under Section 148.’ (Emphasis supplied) 10. In the instant case, admittedly the Ld. AO neither made any addition in relation recorded reasons about share transactions undertaken by the appellant on MCX and nor established any nexus there between

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, PANAJI, PANAJI, GOA vs. BAGKIYA CONSTRUCTIONS PVT. LTD, GOA

The appeal of the Revenue is partly allowed in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2017-2018 Asstt. Commissioner Of Income Tax, Central Circle, Panaji, Goa. . . . . . . . Appellant V/S M/S Bagkiya Construction Pvt. Ltd. Sf-3, Building No.-3. Techno Cidade, Chogam Rd., Alto Porvorim, Goa-403521. Pan: Aaccb9382M . . . . . . . Respondent Represented Assessee By: None For The Respondent Revenue By: Mr Senthil Kumar [‘Ld. Dr’] Date Of Conclusive Hearing : 29/01/2026 Date Of Pronouncement : 27/02/2026 Order Per G. D. Padmahshali; This Revenue’S Appeal Filed U/S 253(2) Of The Income- Tax Act, 1961 [‘The Act’] Challenges The Order Dt. 29/05/2023 Passed U/S 250 Of The Act By Commissioner Of Income Tax(Appeals-2), Panaji [‘Ld. Cit(A)’] Which In Turn Wheeled From The Order Dt. 25/08/2021 Passed U/S 147 Of The Act By Acit, Central Circle, Panaji, Goa [‘Ld. Ao’] Anent To Assessment Year 2017-18.[‘Ay’]

section 131 of the Act, the case of the assessee by an order dt. 26/02/2021 issued u/s 127(2) of the Act was centralised and vide notice dt. 28/03/2021 issued u/s 148 of the Act the reassessment

SALGAOCAR MINING INDUSTRIES PVT. LTD,PANAJI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, MARGAO

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2006-2007 M/S Salgaocar Mining Industries Pvt Ltd. Salgaonkar Bhava, Altino, Panaji, Goa-403001. Pan: Aabcs8862N . . . . . . . Appellant V/S Dy. Commissioner Of Income Tax, Circle-1, Margao, Goa. . . . . . . . Respondent Represented Assessee By: Mr Sukhsagar Syal [‘Ld. Ar’] Revenue By: Ms Rijjula Uniyal [‘Ld. Dr’] Date Of Conclusive Hearing : 20/01/2026 Date Of Pronouncement : 29/01/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income- Tax Act, 1961 [‘The Act’] Impugns The Order Dt. 20/03/2025 Passed U/S 250 Of The Act By Commissioner Of Income Tax(Appeals-2), Panaji [‘Ld. Cit(A)’] Which In Turn Dealt With Order Dt. 20/12/2011 Passed U/S 144 Of The Act By Dcit, Circle-1, Margao Goa [‘Ld. Ao’] Anent To Assessment Year 2006-07.[‘Ay’]

148 of the Act the case of the assessee after recording the reasons reopened u/147 of the Act to reassess the income escaped the assessment. For the non- compliance on the part of the assessee, the assessment u/s 144 r.w.s. 147 of the Act culminated by an order dt. 20/12/2011 wherein the Ld. AO made to additions owning

JENNY ELTON VALES,DONA PAULA vs. ITO, WARD - 5, MARGAO

In the result, the appeal of assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi

2) of the Act. The only contention of the ld. AR before me is that there was no material in possession of AO warranting reassessment by issuing a notice u/s. 148 of the Act. In the present case the time limit to complete assessment u/s. 143 or 144 got expired from the end of two years of assessment year

JENNY ELTON VALES,DONA PAULA vs. ITO, WARD - 5, MARGAO

In the result, the appeal of assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi

2) of the Act. The only contention of the ld. AR before me is that there was no material in possession of AO warranting reassessment by issuing a notice u/s. 148 of the Act. In the present case the time limit to complete assessment u/s. 143 or 144 got expired from the end of two years of assessment year

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI, BELAGAVI vs. M/S POTDAR BROTHERS, BELAGAVI

Appeals of the Revenue are PARTLY ALLOWED for statistical purposes in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

reassessment by issue of notice u/s 148 and consequential assessment u/s 147 of the Act completed wherein a solitary addition of 30% of total payments made to karigars (artisan labours) during the year was made. 3.3 Aggrieved assessee filed an appeal u/s 246A of the Act before first appellate authority which was allowed vide para 4.9 to 4.12 which reads